Privacy

Regulation (EU) 679 dated 27 April 2016 envisages the protection of natural persons with regard to the processing of personal data. Pursuant to art. 13 of Reg. (EU) 2016/679, the processing of personal information is founded on the principles of legality, fairness and transparency, limitation of purpose, minimisation of data, exactness, limitation of retention, completeness, confidentiality and responsibility, in order to safeguard the privacy and rights of the data subject.
The purpose of processing is to include personal data in customer and supplier files in order to manage pre-contractual activities (offers and quotations), contractual sales/purchases of products and services, internal operational or administrative requirements, and the accounting, taxation and statutory aspects and related requirements.
Processing will be carried out, by persons specifically authorised, in the following ways: electronic and hard-copy processing.
Provision of the data is mandatory for the registration of invoices and for all requirements relating to our contractual relationships.
Any failure to provide the data might result in failure to execute or only partial execution of the contract and in failure to continue or only partial continuation of the relationship.
The persons tasked with processing to whom the personal data (identification, accounting and tax data) may be communicated include:

· persons working within the administrative area of our company;
· external persons who may perform fiscal, accounting and IT administrative duties for our company, as well as transport operators;
· banks for the management of payments and collections deriving from execution of the contracts;
· persons whose right of access to the data is granted by specific laws or regulations;
· other persons identified by law.

The data collected will be appropriately retained for a maximum period of 10 years, pursuant to art. 2220 of the Italian Civil Code or, pursuant to art. 13, para. 2, letter a), second part, of Reg. (EU) 2016/679, for a variable period, based on criteria that balance the legitimate interests of the company (linked to tax audits, any special commercial correspondence, such as special and other disputes, late payments, legal matters, periodic purchases, statistical, production and quality management purposes).

There is no possibility that the data will be disseminated (dissemination = communication to unspecified persons)

Pursuant to art. 13, para. 2, letters b), c), d) of Reg. (EU) 2016/679, it is possible to contact the Data Controller to exercise the following rights with regard to the processing of personal data:

· right of access (art. 15);
· right to rectification (art. 16);
· right to erasure (art. 17);
· right to restriction (art. 18);
· right to data portability (art. 20);
· right to object (art. 21);
· right to lodge a complaint with a supervisory authority (art. 77);
· right to revoke consent, in the cases envisaged in art. 6, para. 1, letter a) or art. 9, para. 2, letter a)

The data is processed for the purpose of sending information, communications and material of a commercial, technical or promotional nature relating to our products, applications and services, including newsletters, sent using automated (e-mail, text message etc.) or other instruments (paper-based mail).

The legal base for the processing of Personal Data for these purposes is consent to processing.

The Controller will process Personal Data which may consist of identification such as name and surname, company name, postal address, e-mail address, home and/or mobile telephone number, an ID number, self-declared professional or business category.

DATA SHARING AND THE TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Personal Data may be shared for the purposes indicated in section 3 above, with persons authorised by us to process Personal Data for the activities strictly related to the sending of commercial information, newsletters, etc.

RETENTION OF PERSONAL DATA

Our company will continue to process the Personal Data provided until consent is withdrawn; you may exercise the right to withdraw consent by following the instructions or writing to the address given below.

RIGHTS OF THE DATA SUBJECTS

Pursuant to art. 13(2) lett. b), c), d) of Reg. EU 2016/679, you may contact the Controller to assert the following personal data processing rights:

· right of access (art. 15);
· right to rectification (art. 16);
· right to erasure (art. 17);
· right to restriction (art. 18);
· right to data portability (art. 20);
· right to object (art. 21);
· right to lodge a complaint with a supervisory authority (art. 77);
· right to withdraw consent, in the cases provided for in art. 6(1) lett. a) or art. 9(2) lett. a)

For information or to exercise the rights granted by the GDPR, contact the Caleffi Privacy Team at the following e-mail address: privacy@caleffi.com